A Mahoning County judge has ruled that the city of Youngstown acted lawfully when it reduced the salary of former Municipal Court Clerk Sarah Brown-Clark.

Judge John Durkin granted summary judgment to the city, dismissing Brown-Clark's lawsuit, which sought $28,298 in back pay. Brown-Clark, who served as clerk from 2000 to 2023, argued that she was entitled to 85% of the municipal court judge's salary, citing a state law applicable to cities with populations exceeding 100,000.

However, Durkin determined that Youngstown's population is below 100,000 and that the municipal court's expenditures surpassed its revenues. According to the ruling, state law stipulates that when a city’s population is under 100,000 and court expenses exceed revenue, the clerk’s salary is to be determined by the city's legislative authority.

Brown-Clark, who was elected to a term from 2018 to 2023, contended that the salary reduction in 2019 violated the Ohio Constitution's prohibition against altering an officer’s salary during their term.

The city countered that the reduction was necessary to comply with state law and that the formula used to calculate Brown-Clark's salary remained unchanged. Judge Durkin agreed, stating that while Brown-Clark's salary was lowered, the formula prescribed by state law stayed consistent.

"While Youngstown changed Brown-Clark’s salary in 2019 until the end of her term in 2023 to an amount lower than that paid to her in 2018, Youngstown did not change the formula set forth in R.C. 1901.31(C) to calculate Brown-Clark’s salary," the judge wrote in the ruling.

The judge also referenced financial documents provided by the city, which demonstrated that the municipal court's expenditures exceeded revenues from 2018 to 2023.

Brown-Clark’s lawsuit sought a writ of mandamus, a court order compelling a government official to perform a duty. Durkin denied the writ, stating that Brown-Clark failed to demonstrate a clear legal right to the additional compensation.